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KURLY

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About KURLY

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  1. Hi DX100UK, Are you able to help with the above. I have pasted my defence above.
  2. Hi there, I have drafted my defense below. I must post to the claimant and the court by close of business tonight as 14 days prior to the court date is Monday 18th. Sincere apologies for the delay. I became complacent and nearly forgot. WITNESS STATEMENT I, xxxx, being the Defendant in this case state as follows; I make this Witness Statement in support of my defence dated 7th November 2018 and in response to the claimant’s claim dated 4th September 2018 which was submitted through County Court Business Centre. 1. It is my understan
  3. Hello there, Hope you are both well. Just checking in for further help as I have received my Notice of Allocation to the small claims track and my hearing date is on the 1st April in central London. Just reading the letter again in order to prepare myself for the case and it states that "each party must deliver to the party and to the court office copies of all documents on which that party intends to rely at the hearing no later than 14 days before the hearing." "It also states that this document "must include the statements of all witnesses (including the par
  4. Many thanks for your response. I have completed as above and will make copies and post recorded delivery in the morning. K
  5. Hi there, I thought informing them about the dispute would help but they are unwilling to negotiate as its a bought debt. Yes I have the N180 form
  6. Hi there. Apologies for the delay. I had emergency surgery an only just getting back on my feet. I submitted my defence as above and I received an acknowledgment then a "Notice of proposed allocation to small claims track" form which must be submitted by 12 November!!! I also received the bill from moriarty law and spoke to them about the dispute. They are unwilling to budge as the debt is bought by the company they are representing and they cannot (will not) ask talk-talk for full information/conversation of the dispute. He is only willing to give me a discount on the debt
  7. what about this point here... as the claimant is an assignee. Can I include it? On the alternative, as the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974.
  8. Thank you very much. I will submit my defence now as you have drafted it and continue to check in with progress.
  9. However i would like to also add the paragraph.. "The claim is denied. I have requested information pertaining to the claimants claim by way of a CPR 31.14 request sent on 14.09.2018 and which the claimant received on the 18.09.2018. The claimant has failed to respond" As I feel that the fact they have not supplied these is an important point..
  10. Thanks you so much. I will redraft my defence in the morning and check in on here before submitting it tomorrow. k.
  11. Hello there, As predicted, Moriarty Law has failed to provide the documents requested in the CPR 31.14 I have prepared my defence ready to file 1st thing tomorrow. Can you please help me look over it and add or omit any points.... I again reiterate that this was a dispute with TalkTalk and I truly do not owe any money as the services were not fully provided (As explained in #1) and was wondering if any of that should be mentioned. Many thanks in advance 1. The Defendant contends that the particulars of claim are vague and generic i
  12. Thank you guys, I still haven't received the documents requested in my CPR31 request and don't believe they will send it. Should I wait until the deadline (last minute) or should I send it now. I am really anxious and want to submit my defense asap.. can I submit it today or should I wait until last min..
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